STATE v. ROBERSON, 492 P.3d 620

Troopers stopped Roberson's SUV for an expired tag and a seatbelt violation after observing the vehicle leave a motel known for drug activity.
During the stop the passenger ducked, Roberson and passenger initially could not produce IDs, both appeared nervous, and records checks showed criminal histories including drug convictions.
Roberson told Officer Beyerl there was a small amount of marijuana in the vehicle ashtray; when Beyerl looked inside he smelled a strong odor of raw marijuana and then searched the vehicle further.
The vehicle search ultimately produced evidence that led to a warrant and a search of Roberson's motel room, where additional contraband was found.
The district court granted Roberson's motion to suppress the evidence; the State appealed under 22 O.S. § 1053(5).
The Court of Criminal Appeals reversed, holding the officer had probable cause to search the vehicle despite Oklahoma's medical marijuana law; two justices specially concurred, noting the good-faith-warrant doctrine supported admissibility even if the vehicle search were invalid.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officers had probable cause to search the vehicle given Oklahoma's medical marijuana law	State: Roberson's admission that marijuana was in the ashtray plus the strong odor and totality of circumstances supplied probable cause	Roberson: Legal medical marijuana means presence/odor does not necessarily indicate illegal activity; no basis to assume contraband	Court: Probable cause existed based on admission, odor, and circumstances; suppression order reversed
Whether downstream evidence (motel-room warrant/search) must be suppressed if vehicle search was invalid	State: Even if vehicle search were invalid, the subsequent warrant was obtained/executed in good faith and its fruits are admissible	Roberson: Evidence is fruit of an unlawful search and should be suppressed	Held (concurring view): Good-faith Leon doctrine applies; record contains no bad faith so suppression not required

Schneckloth v. Bustamonte, 412 U.S. 218 (warrant requirement and consent/search framework)
Carroll v. United States, 267 U.S. 132 (automobile exception to warrant requirement)
Florida v. Myers, 466 U.S. 380 (application of automobile exception)
United States v. Arvizu, 534 U.S. 266 (totality-of-circumstances for reasonable suspicion)
Illinois v. Wardlow, 528 U.S. 119 (high-crime-area as contextual factor for suspicion)
United States v. Bradford, 423 F.3d 1149 (driver's admission of marijuana supports probable cause to search vehicle)
Lozoya v. State, 932 P.2d 22 (odor of marijuana constitutes probable cause in Oklahoma)
McGaughey v. State, 37 P.3d 130 (scope of post-stop inquiry and continued detention)